Privacy Notice for Employees and Job Applicants

Examples: Your real name, alias, postal address, unique personal identifier, Internet Protocol (“IP”) address, email address, account name, social security number, driver’s license number, passport number, immigration forms, or other similar identifiers.

• Manage and document your employment or application for employment with us, and employment-related requirements, actions, matters and activities;
• Maintain your employee information in company directories;
• Maintain emergency contact and beneficiary details;
• Administer benefits, such as medical, dental, optical, commuter, and retirement benefits, including recording and processing eligibility of dependents, absence and leave monitoring, and insurance;
• Protect the safety and security of our workforce, guests, property, and assets including monitoring activities in our facilities and activity using our computers, devices, systems, networks, services, communications and other assets and resources;
• Monitor eligibility to work in the U.S.;
• Detect, investigate and prevent policy violations, security incidents, fraud and other unwanted activity;
• Investigate and respond to claims or complaints;
• Comply with and support the enforcement of applicable laws, regulations, policies and procedures; and
• Use in ways we have told you about for our business activities, or for other purposes as permitted by law.

Examples: Your signature, social security number, physical characteristics or description, telephone number, insurance policy number, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

• Manage and document your employment or application for employment with us, and employment-related requirements, actions, matters and activities;
• Maintain your employee information in company directories;
• Maintain emergency contact and beneficiary details;
• Administer benefits, such as medical, dental, optical, commuter, and retirement benefits, including recording and processing eligibility of dependents, absence and leave monitoring, and insurance;
• Protect the safety and security of our workforce, guests, property, and assets including monitoring activities in our facilities and activity using our computers, devices, systems, networks, services, communications and other assets and resources;
• Monitor eligibility to work in the U.S.;
• Detect, investigate and prevent policy violations, security incidents, fraud and other unwanted activity;
• Investigate and respond to claims or complaints;
• Comply with and support the enforcement of applicable laws, regulations, policies and procedures; and
• Use in ways we have told you about for our business activities, or for other purposes as permitted by law.

Examples: Your race, age (40 years or older), color, ancestry, national origin, marital status, medical condition, pregnancy or childbirth, sexual orientation, veteran or military status, gender, physical or mental disability, and religion, to the extent disclosed by the employee.

• Manage and document your employment or application for employment with us, and employment-related requirements, actions, matters and activities;
• Maintain emergency contact and beneficiary details;
• Administer benefits, such as medical, dental, optical, commuter, and retirement benefits, including recording and processing eligibility of dependents, absence and leave monitoring, and insurance;
• Monitor eligibility to work in the U.S.;
• Comply with and support the enforcement of applicable laws, regulations, policies and procedures; and
• Use in ways we have told you about for our business activities, or for other purposes as permitted by law.

Examples: An image of your iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings

• Manage and document your employment or application for employment with us, and employment-related requirements, actions, matters and activities;
• Monitor eligibility to work in the U.S.;
• Comply with and support the enforcement of applicable laws, regulations, policies and procedures;
• Obtain access to certain physical structures and facilities;
• As needed for licensing or compliance with applicable laws or regulations;
• Ensure a safe and efficient working environment; and
• Use in ways we have told you about for our business activities, or for other purposes as permitted by law.

Examples: Your browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement while using a device or application managed by ICW Group.

• Manage and document your employment or application for employment with us, and employment-related requirements, actions, matters and activities;
• Maintain your employee information in company directories;
• Protect the safety, security and efficiency of our workforce, guests, property, and assets including monitoring activities in our facilities and activity using our computers, devices, systems, networks, services, communications and other assets and resources;
• Detect, investigate and prevent policy violations, security incidents, fraud and other unwanted activity;
• Investigate and respond to claims or complaints;
• Comply with and support the enforcement of applicable laws, regulations, policies and procedures; and
• Use in ways we have told you about for our business activities, or for other purposes as permitted by law.

Geolocation Data: Information that can be used to identify the physical location of devices, assets or resources that are managed by ICW Group.

Examples: Location information derived from your device’s GPS coordinates, Cell ID, MAC addresses, Wi- Fi, Bluetooth technology.

• Manage and document your employment or application for employment with us, and employment-related requirements, actions, matters and activities;
• Maintain emergency contact details;
• Protect the safety and security of our workforce, guests, property, and assets including monitoring activities in our facilities and activity using our computers, devices, systems, networks, services, communications and other assets and resources;
• Detect, investigate and prevent policy violations, security incidents, fraud and other unwanted activity;
• Investigate and respond to claims or complaints;
• Comply with and support the enforcement of applicable laws, regulations, policies and procedures; and
• Use in ways we have told you about for our business activities, or for other purposes as permitted by law.

Examples: Audio, electronic, visual, thermal, or olfactory information.

• Manage and document your employment or application for employment with us, and employment-related requirements, actions, matters and activities;
• Maintain your employee information in company directories;
• Maintain emergency contact and beneficiary details;
• Protect the safety, efficiency and security of our workforce, guests, property, and assets including monitoring activities in our facilities and activity using our computers, devices, systems, networks, services, communications and other assets and resources;
• Detect, investigate and prevent policy violations, security incidents, fraud and other unwanted activity;
• Comply with and support the enforcement of applicable laws, regulations, policies and procedures; and
• Use in ways we have told you about for our business activities, or for other purposes as permitted by law.

Examples: Job related data, maintained as part of the employment relationship that could be contained in a job application or resume; an employment contract; a contractor agreement; a performance review; a disciplinary record; photos; information from employee expenses; browsing and search history; payroll and benefits related data; internal and external contact information; or information captured from video, audio, systems, or other forms of monitoring or surveillance.

• Manage and document your employment or application for employment with us, and employment-related requirements, actions, matters and activities;
• Maintain your employee information in company directories;
• Maintain emergency contact and beneficiary details;
• Monitor eligibility to work in the U.S.;
• Comply with and support the enforcement of applicable laws, regulations, policies and procedures; and
• Use in ways we have told you about for our business activities, or for other purposes as permitted by law.

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades or transcripts.

• Manage and document your employment or application for employment with us, and employment-related requirements, actions, matters and activities;
• Monitor eligibility to work in the U.S.;
• Conduct performance-related reviews, including performance appraisals, career planning, skills monitoring, job moves, promotions and staff re-structuring; and
• Use in ways we have told you about for our business activities, or for other purposes as permitted by law.

Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

• Manage and document your employment or application for employment with us, and employment-related requirements, actions, matters and activities;
• Maintain emergency contact and beneficiary details;
• Protect the safety and security of our workforce, guests, property, and assets including monitoring activities in our facilities and activity using our computers, devices, systems, networks, services, communications and other assets and resources;
• Detect, investigate and prevent policy violations, security incidents, fraud and other unwanted activity; and
• Use in ways we have told you about for our business activities, or for other purposes as permitted by law.